Privacy Policy

Privacy Policy

Purpose

Sunshine Hospice Ltd is committed to protecting the privacy of personal information which the organisation collects, holds and administers. The following privacy policy has been provided to explain our practices and outline how and when personal information is collected, stored and distributed by Sunshine Hospice Ltd.

Scope

All Programs

Policy

Sunshine Hospice will endeavour to use all reasonable resources to comply and protect an individual’s personal information in accordance with the Australian Privacy Principles (APP) under the Privacy Act 1988. This privacy policy may be reviewed from time to time. Changes to the privacy policy will be updated on our website. Sunshine Hospice Ltd’s privacy policy will explain the following:

The types of information that Sunshine Hospice Ltd may collect about you and how that information is held;

How you can access the personal information Sunshine Hospice Ltd holds about you and seek to correct such information; and

The way in which you can complain about a breach of your privacy and how Sunshine Hospice Ltd will handle that complaint.

References

Privacy Act 1988

Australian Privacy Principles (APP)

Responsibility

All Workers

Follow procedure

Managers

Implement procedure

Directors

Implement procedure

Definitions

Personal Information: The Privacy Act defines personal information as, “Information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.” Common examples are an individual’s name, signature, address, telephone number, date of birth, medical records, bank account details and commentary or opinion about a person.

Sensitive Information: The Privacy Act defines sensitive information to mean information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices or criminal record. Sensitive information also includes health information and genetic information about an individual that is not otherwise health information.

Procedure

When collecting personal or sensitive information, Sunshine Hospice will collect and protect the privacy of an individual under the thirteen APPs as outlined by the Privacy Act below:

APP 1 – Open and transparent management of personal information

Sunshine Hospice Ltd will manage personal information in an open and transparent way. This includes having a clearly expressed and up to date privacy policy. From time to time, Sunshine Hospice Ltd may have to change or update this policy. The latest version may be found on our website or obtained by contacting the Privacy Officer.

APP 2 – Anonymity or pseudonymity

Wherever it is lawful and practicable in the circumstances, Sunshine Hospice Ltd will give individuals the clear option of interacting by either not identifying themselves or identifying themselves with a pseudonym.

APP 3 – Collection of solicited personal information

Sunshine Hospice Ltd will not collect personal information unless the information is reasonably necessary for, or directly related to, one or more of our functions or activities. The collection of this personal information will be by fair and lawful means and the type of information collected will depend on your dealings with us.

Sunshine Hospice Ltd will not collect sensitive information about an individual unless the individual consents to the collection of the information and the information is reasonably necessary for, or directly related to, one or more of our functions or activities unless the collection of the information is:

required or authorised by or under an Australian law or a court/tribunal order;

a permitted general situation exists in relation to the collection of the information;

a permitted health situation exists in relation to the collection of the information;

we are a not for profit organisation and both of the following apply:

the information relates to the activities of the organisation;

the information relates solely to the members of the organisation, or to individuals who have regular contact with the organisation in connection with its activities.

APP 4 – Dealing with unsolicited personal information

If Sunshine Hospice Ltd receives unsolicited personal information, we will within a reasonable period after receiving the information, determine whether or not we could have collected the information under APP 3 if we had solicited the information. If under consideration for APP 3 it is determined that Sunshine Hospice Ltd could not have collected the personal information and the information is not contained in a Commonwealth record, Sunshine Hospice Ltd will as soon as practicable but only if it is lawful and reasonable to do so, destroy the information or ensure that the information is de-identified.

APP 5 Notification of the collection of personal information

Sunshine Hospice Ltd will ensure that individuals are made aware of the following as soon as practicable:

If we collect personal information from someone other than the individual or if the individual is not aware that we have collected the personal information;

If the collection of the personal information is required or authorised by or under an Australian law or a court/tribunal order — the fact that the collection is so required or authorised (including the name of the Australian law, or details of the court/tribunal order, that requires or authorises the collection);

The purposes for which we collect the personal information;

The main consequences (if any) for the individual if all or some of the personal information is not collected by our organisation;

Any other entity, body or person to which we would usually disclose personal information of the kind collected by our organisation;

This privacy policy contains information about how an individual may access their personal information that is held by Sunshine Hospice Ltd and seek the correction of such information;

This privacy policy contains information about how an individual may complain about a breach of the Australian Privacy Principles, or a registered APP code (if any) that binds the entity, and how the entity will deal with such a complaint;

Whether Sunshine Hospice is likely to disclose the personal information to overseas recipients and outline the countries in which such recipients are likely to be located if it is practicable to specify those countries in the notification or to otherwise make the individual aware of them.

APP 6 Use or disclosure of personal information

Sunshine Hospice Ltd will not use or disclose personal information for a secondary purpose other than the primary purpose for which it was initially collected unless:

The individual has consented to the use of disclosure of the information;

The individual would reasonably expect the information to be disclosed for the secondary purpose;

The use or disclosure of the information is required or authorised by or under an Australian law or a court/tribunal order;

A permitted general situation exists in relation to the use or disclosure of the information;

A permitted health situation exists in relation to the use or disclosure of the information;

The disclosure of the information is believed to be reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body;

APP 7 Direct marketing

Sunshine Hospice Ltd may use or disclose personal information (other than sensitive information) about an individual for the purpose of direct marketing if:

The information is collected from the individual;

The individual would reasonably expect Sunshine Hospice Ltd to use or disclose the information for that purpose;

Sunshine Hospice Ltd will provide a simple means by which an individual may easily request not to receive direct marketing communications.

APP 8 Cross-border disclosure of personal information

Sunshine Hospice Ltd may enter into arrangements with third parties to store data we collect, and such data may include personal information, outside of Australia. Sunshine Hospice Ltd will take reasonable steps to ensure that the third parties do not breach the APPs. Sunshine Hospice Ltd will ensure the third party is bound by privacy protection commitments which are the same as which Sunshine Hospice Ltd practises.

APP 9 Adoption, use or disclosure of government related identifiers

Sunshine Hospice Ltd will not adopt a government related identifier of an individual as its own identifier of the individual unless the adoption of the government identifier is required or authorised by or under an Australian law or a court/tribunal order.

APP 10 Quality of personal information

Sunshine Hospice Ltd will take reasonable steps to ensure that the personal information it collects, uses or discloses is accurate, up to date, complete and has regard to the purpose of the use or disclosure.

APP 11 Security of personal information

The security of personal information is a significant issue for Sunshine Hospice Ltd and as such will take all reasonable steps in the circumstances to protect information from misuse, interference, loss, unauthorised access, modification or disclosure.

In the event that personal information is no longer required for any purpose by the Sunshine Hospice Ltd and the information is not required to be retained by or under an Australian law or a court/tribunal order, all reasonable steps will be taken in the circumstances to destroy the information or to have it de-identified

Patient Information

The patient care provided by Sunshine Hospice Ltd is paramount to achieving the mission of the organisation. As part of providing the best possible care to a patient, a team approach may be required and subsequent sharing of personal information may be required. In this instance, Sunshine Hospice Ltd will take reasonable steps in the circumstances to ensure the following:

To keep current patient records and previous patient records secure;

Only those health professionals attending to the care of the patient will have access to a patient’s personal information;

Sunshine Hospice Ltd may provide personal information about a patient’s condition to their parent, child, spouse, relatives, close personal friends, guardians or a person exercising your power of attorney unless you tell Sunshine Hospice Ltd that you do not want your personal information disclosed to such a person.

A patient or their representative has the right to access their personal information. Access to these records must be done in consultation with the Hospice Manager who will answer questions regarding a patient file.

APP 12 Access to personal information

Sunshine Hospice Ltd will provide access to an individual’s personal information upon written request by the individual. Sunshine Hospice Ltd has the right to refuse an individual access to their personal information as per the Privacy Act 1988 and APP 12.3.

If the information held by Sunshine Hospice Ltd about an individual, having regard for which the information is held, is inaccurate, out of date, incomplete, irrelevant, misleading or the individual requests the entity to correct the information, Sunshine Hospice Ltd will take such steps as reasonable in the circumstances to correct the information to ensure that, having regard to the purpose for which it is held, the information is accurate, up to date, complete, relevant and not misleading.

If Sunshine Hospice Ltd does not agree to a request for change to your personal information as per your request, we will permit you to make a statement of the requested changes and we will enclose this with your record.

Some of our pages contain links to other sites whose information practices may be different from ours. Visitors should consult the other sites' privacy notices as we have no control over information that is submitted to, or collected by, these third parties. We may sometimes offer content (e.g., contests, sweepstakes, or promotions) that are sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties may obtain personally identifiable information that visitors voluntarily submit to participate in the site activity. We have no control over how these third parties use this information.

Cookies

To enhance your experience with our sites, many of our web pages use "cookies”. Cookies are text files we place in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information unless you choose to provide this information to us by, for example, registering at one of our sites. However, once you choose to furnish the site with personally identifiable information, this information may be linked to the data stored in the cookie. We use cookies to understand site usage and to improve the content and offerings on our sites. For example, we may use cookies to personalise your experience at our web pages (e.g., to recognise you by name when you return to our site), save your password in password-protected areas, and enable you to use shopping carts on our sites. We also may use cookies to offer you products, programs, or services.

How to contact us

If you wish to contact Sunshine Hospice Ltd about its privacy policy or the way in your personal information has been handled please contact our Privacy Officer via the following: